LEGAL · 02

Privacy.

How we handle your data

We don't sell data

Your personal information is never sold to third parties. We collect only what is necessary to operate the payment network.

On-chain only

Transaction records live on the Monad blockchain. We do not maintain a separate centralized database of your payment history.

No KYC v1

Zylo Pay v1 does not require identity verification. Access is permissionless via passkey authentication.

Open source

Our smart contracts are verified and publicly auditable on Monad. Transparency is a feature, not a tradeoff.

01

Data We Collect

Zylo Pay collects the minimum data necessary to operate the payment network: — Passkey credentials: Public key identifiers for authentication. Private keys never leave your device. — Wallet addresses: Your Monad-compatible wallet address, derived from your passkey. — Device metadata: Browser type, operating system, and NFC capability for wallet pass generation. — Merchant registration data: Business name and wallet address provided during registration. We do not collect your real name, email, phone number, or government ID in version 1 of the protocol.
02

How We Use It

Data collected is used exclusively for: — Generating and delivering Apple Wallet and Google Wallet passes containing your payment authorization. — Relaying signed payment authorizations to the Monad blockchain on your behalf. — Displaying transaction history and merchant information within the Zylo Pay applications. — Monitoring network health, detecting fraud, and improving service reliability. We do not use your data for advertising, profiling, or behavioral analytics.
03

On-Chain Data

Zylo Pay settles payments on the Monad blockchain, a public distributed ledger. You acknowledge that: — All transaction data (sender address, recipient merchant ID, amount, timestamp) is permanently and publicly recorded. — On-chain data cannot be deleted, modified, or made private after settlement. — Anyone can view your transaction history by querying your wallet address on a block explorer. — Zylo Pay has no ability to remove or obscure on-chain records. This is an inherent property of blockchain-based systems and not a limitation of Zylo Pay's privacy practices.
04

Third Parties

We may share limited data with the following categories of third parties: — Infrastructure providers: Cloud hosting and relay infrastructure necessary to operate the payment network. — Wallet pass platforms: Apple and Google, as required to generate and deliver wallet passes to your device. — Blockchain validators: Monad network validators process and confirm transactions. — Legal compliance: We may disclose information if required by law, subpoena, or court order. We do not share data with advertisers, data brokers, or analytics companies.
05

Your Rights

Depending on your jurisdiction, you may have the following rights: — Access: Request a copy of the personal data we hold about you. — Deletion: Request deletion of off-chain personal data. Note that on-chain transaction records cannot be deleted. — Portability: Export your transaction data in a machine-readable format. — Objection: Object to processing of your data for specific purposes. To exercise any of these rights, contact us at privacy@zylopay.com. We will respond within 30 days.
06

Contact

For privacy-related inquiries: — Email: privacy@zylopay.com — Entity: Uplevel LLC — Address: Wilmington, Delaware, United States For security vulnerabilities, contact security@zylopay.com.

ON-CHAIN TRANSPARENCY

All Zylo Pay transactions settle on the Monad public blockchain. Transaction data — including wallet addresses, merchant IDs, amounts, and timestamps — is permanently recorded and publicly accessible. This transparency is by design. The settlement contract is verified and auditable at monadscan.com.

Effective Date: March 22, 2026 · Zylo Pay / Uplevel LLC